Sanctions

Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned the Foxtrot Network, a Sweden-based transnational criminal organization (TCO), along with its fugitive leader, Rawa Majid. The network, involved in drug trafficking and violent crimes across Europe, orchestrated an attack on the Israeli Embassy in Stockholm in January 2024 on behalf of Iran.

Despite the Justice Department's dismantling of inter-agency cooperation to enforce sanctions and combat corruption, cases begun before the change of regime continue to wend their way though the courts. March 10, The U.S. District Court for the Southern District of New York granted the government’s motion to strike the ownership claim of Eduard Khudainatov and Millemarin Investments Ltd. concerning the Motor Yacht Amadea.

President Donald Trump has issued contradictory signals regarding sanctions on Russia, simultaneously threatening punitive economic measures while reportedly exploring avenues for relief. On Friday, Trump warned of large-scale banking sanctions, tariffs, and additional economic penalties on Moscow in an effort to push Russia and Ukraine toward a peace settlement. Despite his threats of increased economic pressure on Russia, reports indicate that the Trump administration is simultaneously considering sanction relief.

In a further sign of the Trump White House's rapprochement with the Kremlin, The Treasury and Department of State have been ordered to compile a  list of sanctions to be lifted. Europe may soon find itself enforcing measures against Moscow alone.

Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on seven senior members of Ansarallah, commonly known as the Houthis, for their roles in smuggling military-grade weapons into Houthi-controlled areas of Yemen and negotiating arms procurement deals with Russia. Additionally, OFAC has designated a Houthi-affiliated operative and his company for recruiting Yemeni civilians to fight for Russia in Ukraine, generating revenue to support Houthi militant operations.

Tuesday Beijing announced several export control and sanctiosn measures on US firms, including the addition of 10 U.S. firms to China’s Unreliable Entity List, and restrictions on certain U.S. companies in the high-tech sector. Firms added to the Unreliable Entity List are added for their involvement in arming the Taipei government, while the Export Control List entries are prohibited from importing dual-use items from the PRC.

China's Ministry of Commerce (MOFCOM) announced on Tuesday that it has launched an anti-circumvention investigation into certain optical fiber products imported from the US, marking the first time that China has initiated such an investigation. The ministry said in a notice that it has learned that relevant fiber optic products are suspected of circumventing China's anti-dumping measures, and it initiated the probe at the request of domestic industries. Based on the investigation's findings, a decision will be made on whether to impose anti-circumvention measures against the US, the notice said.

Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned six entities based in Hong Kong and the People’s Republic of China (PRC) for procuring unmanned aerial vehicle (UAV) components on behalf of Iranian drone builder PKGB. This action builds upon prior designations, including those in February 2024 targeting Hong Kong-based procurement networks working for PKGB. The latest measures are part of efforts to disrupt PKGB’s attempts to reestablish supply chains and continue obtaining critical UAV parts from foreign sources.

The United States has reimposed strict sanctions on Venezuela’s oil sector, revoking all licenses granted under the Biden administration. President Donald Trump announced the policy shift, effective March 1, 2025, citing the Venezuelan government’s failure to uphold its commitments under a previous agreement. “I am hereby reversing the concessions that Crooked Joe Biden gave to Nicolás Maduro, of Venezuela, on the oil transaction agreement, dated November 26, 2022,” Trump stated.

As Moscow's war against Ukraine enters its fourth (or eleventh) year, the European Commission announced the Council's adoption of the 16th sanctions package against Russia. As is customary, the United Kingdom announced complementary sanctions. Unlike with prior initiatives, the United States did not join in the effort, reflecting the new rapprochement between Washington and the Kremlin. The 16th sanctions package intensifies restrictions on key sectors of Russia's economy, including energy, trade, transport, infrastructure, and financial services.

In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States. A note compiled by Mark Handley of Duane Morris, London, tallies combined enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ, as compared to their European peers.

Monday 24 February, Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the StateDepartment, imposed sanctions on more than 30 individuals, entities, and vessels for their roles in facilitating the sale and transportation of Iranian petroleum-related products. This latest round of sanctions includes oil brokers based in the United Arab Emirates (UAE) and Hong Kong, tanker operators in India and the People's Republic of China (PRC), as well as senior officials and subsidiaries of Iran's National Iranian Oil Company (NIOC).

Thursday, OFAC launched its new File Finder application  for use on the OFAC website. The rowser-based application allows users to search through and efficiently navigate all of OFAC's website content.

Following on President Trump's Executive Order imposing sanctions on the International Criminal Court, the Treasury Department added Karim Asad Ahmad Khan to the Specially Designated National List. Mr. Khan, a British Subject, has served as the chief prosecutor of the International Criminal Court in The Hague since 2021. In May 2024, he announced the ICC's decision to apply for arrest warrants for Israeli Prime Minister Benjamin Netanyahu, Israeli Defense Minister Yoav Gallant, and Hamas leaders Yahya Sinwar, Mohammed Deif, and Ismail Haniyeh for alleged war crimes and crimes against humanity.

The Justice Department announced Thursday that Dominican Republic authorities seized a Dassault Falcon 2000EX aircraft used by Petroleos de Venezuela, S.A. (PdVSA), the sanctioned Venezuelan state-owned oil and natural-gas company, at the request of the U.S. government based on violations of U.S. export control and sanctions laws. The Justice Department previously announced in September 2024 the seizure of a Dassault Falcon 900EX aircraft in the Dominican Republic that was owned and operated for the benefit of Nicolás Maduro Moros and persons affiliated with him in Venezuela.

Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on an international oil smuggling network that has facilitated the shipment of millions of barrels of Iranian crude oil, worth hundreds of millions of dollars, to the People’s Republic of China (PRC). This action aligns with the February 4 National Security Presidential Memorandum, which mandates maximum economic pressure on Iran to prevent its nuclear advancement and regional destabilization.

Tuesday February 4th the White House  issued a National Security Memorandum (NSM) directing multiple federal agencies to impose maximum pressure on the Government of the Islamic Republic of Iran. The memorandum outlines aggressive measures aimed at denying Iran all paths to a nuclear weapon, countering its regional influence, and disrupting its financial and military networks.

January 27, Canada announced it is imposing new sanctions against 10 individuals and 12 entities under the Special Economic Measures (Belarus) Regulations in response to ongoing gross and systematic human rights violations committed by the Lukashenko regime in Belarus, as well as its support of Russia’s violation of Ukraine’s sovereignty and territorial integrity. These sanctions are being announced in coordination with the United Kingdom.  Customarily, such announcements are coordinated with US sanctions authorities in the Departments of State and Treasury., but action in Washington was lacking

OFAC is sanctioning Abdel Fattah Al-Burhan (Burhan), the leader of the Sudanese Armed Forces (SAF), under Executive Order (E.O.) 14098, “Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition.” This action follows the designation of the leader of the Rapid Support Forces (RSF), Mohammad Hamdan Daglo Mousa , on January 7, 202 .[13310]. In addition, OFAC is sanctioning one company and one individual involved in weapons procurement on behalf of the Defense Industries System (DIS), a procurement arm of the SAF that OFAC sanctioned in June 2023.

The United States today designated eight individuals who organized and executed the commemoration of Republika Srpska (RS) Day on January 8-10, 2024 in support of RS President Milorad Dodik’s secessionist agenda.  Seven of those sanctioned today also helped plan and organize the 2025 commemoration.  RS commemorations have been determined to be unconstitutional by the Constitutional Court.  Directed and overseen by Dodik, they are emblematic of Dodik’s longstanding efforts to undermine the 1995 Dayton Peace Agreement, a cornerstone for regional peace and security. 

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